People v. Oneal
64 Cal.App.5th 581
| Cal. Ct. App. | 2021Background
- Willie Donte Oneal was charged with multiple burglaries, robberies, and related counts arising from incidents in October 2017; he later pled no contest to attempted second‑degree robbery and first‑degree burglary and admitted enhancements.
- Oneal initially pleaded not guilty by reason of insanity; the court appointed two experts (Terrell, psychiatrist; Kendall, psychologist) who concluded he was legally sane at the times of the offenses and attributed his conduct primarily to methamphetamine use and criminal history, not psychosis.
- Defense later sought pretrial mental‑health diversion under Penal Code §1001.36; defense retained psychologist Blak who opined Oneal’s schizoaffective disorder significantly contributed to the offenses.
- The trial court denied diversion on two statutory grounds: (1) Oneal’s mental illness was not a significant factor in his crimes; and (2) Oneal would pose an unreasonable risk to public safety if treated in the community.
- On appeal, Oneal contended the court improperly relied on the §1026/§1027 insanity reports (violating due process) and that the record did not support the dangerousness finding. The Court of Appeal found the challenge to report reliance forfeited but reached the merits, held the reports were properly considered, and affirmed because substantial evidence supported the non‑significance finding; the dangerousness ruling was unnecessary to the result.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the court could consider court‑appointed §1026/§1027 insanity reports when ruling on §1001.36 diversion | People relied on Terrell and Kendall reports showing offenses were driven by substance use/criminal propensity and thus relevant to diversion eligibility | Oneal argued reliance on insanity reports deprived him of due process and those reports did not support denial | Forfeiture of objection, but on the merits the court may consider such reports where relevant; the reports were properly considered under §1001.36’s "any relevant and credible evidence" standard |
| Whether Oneal’s mental disorder was a "significant factor" in the commission of the offenses (eligibility under §1001.36(b)(1)(B)) | Oneal’s disorder did not substantially contribute; experts Terrell and Kendall so opined | Defense expert Blak said schizoaffective disorder significantly motivated behavior (demeanor, witnesses) | Substantial evidence supports the trial court’s finding that schizoaffective/psychotic disorder was not a significant factor; denial of diversion affirmed on this independent ground |
| Whether the record supports a finding Oneal posed an unreasonable risk to public safety under §1001.36(b)(1)(F) (per §1170.18 definition) | People argued court’s dangerousness finding supported denial but appellate decision need not reach it because other ground suffices | Oneal argued no support: his record had no "super‑strike" violent felonies as required by §1170.18(c) | Appellate court observed the dangerousness finding was dubious under the statutory "super‑strike" framework but deemed any error harmless because the non‑significance finding independently supports denial |
| Standard of review for eligibility factfinding under §1001.36 | People: deferential review; trial court has discretion to deny diversion | Oneal: challenges to factual findings should be reversed if not supported | Court treated the mental‑illness significance determination as a factual finding reviewed for substantial evidence and discretionary rulings for abuse of discretion |
Key Cases Cited
- People v. Frahs, 9 Cal.5th 618 (summarizes purpose and statutory requirements for pretrial mental‑health diversion)
- People v. Moine, 62 Cal.App.5th 440 (discusses discretionary review of dangerousness determination under §1001.36)
- People v. Partida, 37 Cal.4th 428 (forfeiture rule requiring objection at trial to preserve appellate claim)
- People v. Cromer, 24 Cal.4th 889 (substantial‑evidence review of factual findings)
- People v. Jefferson, 1 Cal.App.5th 235 (treats dangerousness determination as discretionary)
- People v. Hall, 247 Cal.App.4th 1255 (same: judicial discretion re risk to public safety)
- People v. Panah, 35 Cal.4th 395 (trial court’s evidentiary relevance determinations reviewed for abuse of discretion)
- People v. Valencia, 3 Cal.5th 347 (explains "super‑strike" felonies in §667 framework)